On this episode of The Ethics Experts, Nick speaks with Karin Volo about how Marketing and HR now have a seat at the table with IT, profits, and productivity!
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Where does “tone at the top” start? With any public and most private U.S. companies, it is at the Board of Directors. But what is the role of a company’s Board in compliance? First a Board should not engage in management but should engage in oversight of a CEO and senior management. The Board does this through asking hard questions, risk assessment and identification.
Initially it must be important that the Board receive direct access to such information on a company’s policies on this issue. The Board must have quarterly or semi-annual reports from a company’s CCO to either the Audit Committee or the Compliance Committee. Every Board should create a Compliance Committee to deal with compliance issues, as an Audit Committee may more appropriately deal with financial audit issues. A Board Compliance Committee can devote itself exclusively to non-financial compliance. The Board’s oversight role should be to receive such regular reports on the structure of the company’s compliance program, its actions and self-evaluations. From this information the Board can give oversight to any modifications to managing FCPA risk that should be implemented. CCO reporting to the Compliance Committee must be structured carefully to promote ethics and compliance.
Three key takeaways:
Welcome to a special five-part podcast series, From the Code of Conduct to Risk Assessment to Continuous Improvement: A Conversation with Convercent and StoneTurn. This week’s podcast series is jointly sponsored by Convercent and StoneTurn. In this podcast series we will explore the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on investigations, data analytics, evaluating compliance programs, internal reporting and corporate culture. Participants in this podcast series include: from Asha Palmer, Chief Compliance Officer and EVP at Convercent; and Rex Homme, Michele Edwards, and Stephen Martin, all Partners at StoneTurn. In this first episode, we take a deep dive with Rex Homme into conducting investigations and ensuring consistent outcomes.
Join us tomorrow, as Asha Palmer, EVP at Convercent discusses best practices in internal reporting.
Resources
For more information on StoneTurn, check out their website, here.
For more information on Convercent, check out their website, here.
To download a copy of the Convercent Interactive Self-Assessment based on the 2020 Update to the Evaluation of Corporate Compliance Programs, click here.
In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for March 2020.
Some of the highlights include:
Resources
To a copy of the Top 10 International Anti-Corruption Developments for March 2020 Newsletter click here.
